Bamidele Arike Kolapo - Page 4




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          of 2003 and July, August, and September of 2004.  Petitioner                
          worked in Parsippany during the remaining 9 months of each year.            
               Petitioner timely filed Federal income tax returns in which            
          she reported adjusted gross income of $24,719 for 2003 and                  
          $29,207 for 2004.  On March 20, 2006, respondent issued two                 
          separate notices of deficiency for 2003 and 2004, respectively.             
          Petitioner timely filed a petition with this Court regarding both           
          2003 and 2004.  The following miscellaneous deductions remain in            
          dispute:3                                                                   

                    Miscellaneous Expense     2003       2004                         

                   Vehicle expense           $9,040     $9,519                        
                   Parking fees, tolls,      98         320                           
                   transportation                                                     
                   Business expenses         4,800      4,580                         
                   Work materials, work      5,800      5,644                         
                   clothes, and                                                       
                   cleaning expenses                                                  
               Petitioner provided no receipts or contemporaneous records             
          to substantiate any of her claimed miscellaneous expenses.  In              
          January 2005, after the IRS informed petitioner her returns were            
          being audited, and on the recommendation of her accountant,                 
          petitioner prepared logs from memory relating to her                        

               3 Sec. 67(a) allows miscellaneous itemized deductions only             
          to the extent that the aggregate of such deductions exceeds 2               
          percent of adjusted gross income.  Whether the miscellaneous                
          deductions are allowed will affect whether it would be more                 
          beneficial for petitioner to itemize or claim the standard                  
          deduction in either 2003 or 2004.                                           





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